At its September 2021 meeting, WADA’s Executive Committee approved a change removing athletes’ real-time access permissions to their Athlete Biological Passport (ABP) hematological data in ADAMS. Evidence from the Operation Aderlass investigation revealed that some athletes were able to monitor this data in ADAMS, with the help of support personnel, in order to calibrate their doping strategy and avoid detection. Further evidence shows athletes are sometimes pressured to reveal their ABP blood data publicly or to their sporting teams or associations precisely because of their direct access to it, leading to undue stigmatization and discrimination. The change brings access to ABP blood data in line with most other anti-doping data, including laboratory results, that athletes equally do not have access to in ADAMS.
Who does this change affect?
The change affects a very small proportion of high-level athletes that have a hematological passport and an active ADAMS account. WADA encourages ADOs/Passport Custodians to inform this athlete group of the change in advance.
Can athletes still request a copy of their ABP blood data?
Yes, athletes have a right to access their personal information under the International Standard for the Protection of Privacy and Personal Information (ISPPPI), as well as under applicable privacy and data protection laws. Under the ISPPPI, ADOs are required to provide a contact point where athletes can submit this type of request to them. In the context of an ADRV proceeding, athletes also have a right to receive relevant laboratory results that are the subject of an ADRV charge in the form of laboratory and ABP documentation packages.
The right of access to personal information does not require that data be directly or immediately accessible to athletes via ADAMS. In the case of ABP blood data, removing direct access via ADAMS removes the possibility for ill-intentioned individuals to view their blood values in real time, which reduces the value of such information as part of a doping strategy. It should also act as a significant deterrent to such individuals, given they will need to identify themselves to the ADO when making their access request, and would need to make multiple requests over time in order to attempt to use this data for nefarious purposes.
How will athletes be alerted to potential medical conditions uncovered by their ABP blood data?
The purpose of the ABP is to uncover doping and not to serve as a health monitoring tool. It is important that ADOs/Passport Custodians educate athletes to ensure that they undergo regular health monitoring and not rely on the ABP for this purpose.
Recognizing that ABP blood data may nonetheless incidentally uncover medical conditions, Annex C of the International Standard for Results Management (ISRM) defines a process to alert athletes of potential medical conditions requiring further examination (see ISRM comment to Article C.2.3). Atypical passports are reviewed by experts who communicate any potentially relevant medical opinions to the athlete with the assistance of the Passport Custodian. This process has proven successful and effective in identifying and communicating relevant pathologies to athletes and does not depend on athlete access to this data in ADAMS.
How should ADOs respond to requests for ABP blood data?
Detailed guidance is available to ADOs in the ISPPPI Guidelines (see pages 69-76). In short, each request must be assessed on a case-by-case basis and responded to in accordance with the ISPPPI and applicable laws. The Passport Custodian will be the ADO with primary responsibility for responding to access requests related to a passport under its custody, and can use the ADAMS’ reporting functions to extract the relevant information from ADAMS (see here for instructions). To the extent WADA receives a request from an individual directly, WADA will notify the Passport Custodian without prejudice to its ability to respond to the request independently, as provided for in the Agreement Governing the Use of ADAMS.
Can a request for a copy of ABP blood data be refused?
Exceptions under the ISPPPI permit access to personal information to be refused or delayed where such access would undermine the integrity of the anti-doping system. Exceptions under national privacy and data protection or anti-doping/sport laws may similarly provide scope for such refusal or delay in specified circumstances. While exceptions to the right of access must generally be applied narrowly, it is appropriate for ADOs to carefully consider whether any such exception applies before providing a copy of ABP blood data in response to a request.
WADA is not able to provide a blanket rule for when a request can be refused or delayed because each access request must be assessed individually, and because exceptions permitting or requiring an ADO to refuse or delay a response to such a request will vary under applicable laws. WADA instead encourages ADO to collaborate and communicate with WADA on this issue with a view to developing harmonized guidelines and practices for the anti-doping community.